Defendant was convicted of obstruction of justice for giving police a fake name and an incorrect birth date after he was arrested. The appellate court reversed, finding that the evidence was insufficient to convict as a matter of law because the State failed to establish the “material impediment” element of the offense and remanded for re-trial. The Supreme Court affirmed in part and reversed in part, affirming the reversal of the conviction but finding that the double jeopardy claims barred retrial. (THEIS, NEVILLE, OVERSTREET, CUNNIGHAM, ROCHFORD, and O’BRIEN, concurring)
Defendant was found guilty of being an armed habitual criminal and challenged the sufficiency of the evidence on appeal. The appellate court found the evidence was sufficient but reversed and remanded for a new trial due to the trial court’s bias in favor of police testimony. The Supreme Court reversed the appellate court’s finding of bias, noting that the trial court’s comments did not reflect a pro-police bias, but rather reflected a deliberation of the proper factors in its credibility determination and that there was no other evidence in the record indicating that the trial court displayed favoritism for police testimony. (THEIS, OVERSTREET, HOLDER WHITE, ROCHFORD, and O’BRIEN, concurring. NEVILLE took no part in the decision.)
Defendant, who was a juvenile at the time of the offense, was convicted of murder. The trial court denied his motion for leave to file a successive post-conviction petition challenging his sentence on the grounds that the trial court had failed to make a finding of permanent incorrigibility and had not addressed the attendant characteristics of youth during sentencing. The appellate court reversed, and the Supreme Court granted the State’s petition for leave to appeal. The Supreme Court reversed the judgment of the appellate court and remanded to the appellate court for further proceedings, finding that because the pre-sentence investigative report contained evidence regarding the defendant’s age, maturity, and other circumstances, the defendant received the constitutionally required procedure under Miller. (THEIS, NEVILLE, OVERSTREET, and HOLDER WHITE, concurring. ROCHFORD and O’BRIEN took no part in the decision.)
Petitioner filed a motion seeking leave to file a successive post-conviction petition challenging his conviction for murder on the grounds that recent scientific studies had discredited forensic bite mark opinion testimony and raising a claim of actual innocence as well as a due process claim and three additional claims. The trial court denied the motion and the appellate court reversed in part and affirmed in part. The Supreme Court found that absent any allegation that the State knowingly used false bite mark testimony, defendant had not pled a cognizable due process claim under Illinois law and his motion could not satisfy the cause and prejudice test. The court also concluded that defendant did not meet the high standard for setting forth a claim of actual innocence. The court remanded to the appellate court to consider the remaining claims that had not been addressed in the appellate court’s prior opinion. (THEIS, NEVILLE, OVERSTREET, and HOLDER WHITE, concurring. ROCHFORD and O’BRIEN took no part in the decision)
A consolidated case where defendants, who were both sentenced to life in prison for separate murders committed when they were 19 years old, appealed from judgments denying them leave to file successive post-conviction petitions challenging their sentences. The Supreme Court found that neither defendant sufficiently pled cause for filing a successive post-conviction petition, explaining that Miller did not change the law applicable to discretionary sentences imposed on young adult offenders and, as a result, did not provide cause for the filing of successive post-conviction petitioners. (THEIS, OVERSTREET, HOLDER WHITE, CUNNINGHAM, ROCHFORD, and O’BRIEN, concurring)
Defendant, who was 19 years old at the time of the offense, pled guilty to first-degree murder and was sentenced to 40 years in prison. The trial court dismissed Defendant’s post-conviction petition and defendant appealed arguing that section 5-4.5-115 of the Unified Code of Corrections violates the equal protection clause of the Illinois and U.S. Constitutions because it grants parole review only to young offenders sentenced after a certain date and not to those, like defendant, who were sentenced before that time. The appellate court affirmed, holding that section 5-4.5-115 does not violate equal protection principles because there were multiple rational bases supporting the legislature’s prospective application of the statute. (McDADE and ALBRECHT, concurring)
Defendant was charged with two counts of driving under the influence and was found guilty after a bench trial. Defendant appealed, arguing that the trial court should have dismissed the charges against him because his speedy-trial rights were violated. The appellate court agreed and reversed defendant’s conviction, finding that a 41-day delay was caused by the State’s filing of a motion in limine and the trial court’s delay in ruling on the motion and that the delay was not attributable to the defendant. (ALBRECHT and PETERSON, concurring)
In prosecution on charge of felon in possession of weapon charge, Dist. Ct. did not err in rejecting defendant’s Batson challenge to prosecutor’s use of peremptory challenge against one black juror, under circumstances where: (1) prosecutor struck all three black jurors in 39-person venire panel; (2) said juror claimed that she did not use internet in response to Dist. Ct. admonishment to venire that they not use internet for any purpose related to or surrounding case; and (3) prosecutor explained that he struck juror because he did not believe people when they said that they do not use internet. While Dist. Ct. made observation when evaluating prosecutor’s explanation for use of said peremptory challenge that prosecutor was also African-American, no part of Dist. Ct.’s reasoning relied on race of prosecutor as reason to deny defendant’s challenge. Moreover, Dist. Ct. could properly find that prosecutor was credible in claim that he uses confessed internet usage as proxy for truthfulness, and that prosecutor has per se rule that he does not believe those who may deny internet usage. Fact that prosecutor might be incorrect that jurors denying using internet are lying does not require different result, where prosecutor’s theory is not so improbable that no reasonable jurist could have found it credible.
Defendant appealed from the dismissal of his post-conviction petition at the first stage, arguing that the cause should be remanded for further second-stage proceedings where privately-retained counsel failed to file a certificate pursuant to SCR 651(c) and failed to amend the defendant’s pro se petition. The appellate court reversed and remanded, finding that post-conviction counsel failed to file the required certificate and that it could not determine from the record that counsel fulfilled his duties under the rule. (PETERSON, concurring and BRENNAN, specially concurring)
Defendant was found guilty of criminal sexual assault and sentenced to 10 years in prison. He argued on appeal that the trial court erred when it questioned the State’s witnesses and that the trial court improperly relied on evidence outside of the record during sentencing. The appellate court affirmed, finding that defendant forfeited any objection to the court’s questioning of witnesses and that the court’s actions were not improper under a plain error review. The appellate court also found no error in the trial court’s consideration of the sentencing factors. (DeARMOND and TURNER, concurring)
